Q: Can you clarify the Cresol in insulin concentration? For
example, an insulin drip would only contain 1ml of insulin (w/ cresol) diluted
to 100ml in NS. Is the diluted drip required to be managed as "hazardous
waste"? Same question for TPN's that contain chromium and selenium. The
vials "prior to dilution in TPN" are hazardous waste but what about a
TPN solution (2-3 Liters) that needs to be wasted?

Q: Our waste disposal company said Barium is not a hazardous
waste. I checked and there is no "exception" for RCRA listed chemical
in our state (Florida) is it possible that the radiology product we use is a
lower concentration than 100mg/l regulatory set level?

Q: What is your recommendation for disposal of NIOSH listed
"Hazardous Drugs”? Do you know if the ASHP has a list of "hazardous
drugs" that differ from the NIOSH list and what list should be followed?

Q: How did you "label" your UPW items? For example
"black dot" items with a sticker. Did you "label" these
products electronically in the computer systems? Did you label the hazardous drugs
(NIOSH) excluding chemo's that are already labeled?

Q: The major question for many facilities is in fact the
disposal of controlled substances, what is the potential harm of destruction
via the sewer system?

Q: What do you do with 1/2 tubex of demerol? Where do you
waste it?

Q: The requirement for special waste of pharmaceuticals that
are aerosols is a state requirement only?

Q: Do Home Care companies have a responsibility for RCRA
items dispensed to patient or is it the patient's responsibility?

Q: If I choose to ship ALL pharmaceutical waste to a RCRA
incinerator, what "manifesting" must be done? Do I have to do ANY
manifesting, or is a blanket (percentage) manifest adequate?

Q: What are you doing about diversion of controlled
substances if RCRA type med and needs to be placed in black container when
nursing is "wasting" med ?

Re: Pharmaceutical Waste Webinar

A: As I noted in my presentation the only thing that big pharma has done is assist with the funding for Smarxt. A system that provides a means for homes to dispose of medications via the municiple trash system. I had the opportunity to meet with the folks from Big Pharma in DC a couple of years ago and their response to this problem is that there isn't a problem and they have done all they are going to do. So the answer is yes to a certain point and NO on a larger point. In my opinion they need to eliminate sample medications and set fourth a standard for vouchers.

Re: Pharmaceutical Waste Webinar

Q: Can you clarify the Cresol in insulin concentration? For example, an insulin drip would only contain 1ml of insulin (w/ cresol) diluted to 100ml in NS. Is the diluted drip required to be managed as "hazardous waste"? Same question for TPN's that contain chromium and selenium. The vials "prior to dilution in TPN" are hazardous waste but what about a TPN solution (2-3 Liters) that needs to be wasted?

A: Once a product is dispensed and used or partially used for patients, it now becomes rubbish and does not need to be managed as RCRA. As noted in my slides M-cresol is a D-listed chemical and it has to be 200mg/liter. If the concentration is lower then it becomes normal waste. You will have to calculate the concentration out based on the concentration in your specific insulin type. In most instances, drips are way too diluted however pens and vials at the threshold. As noted for insulin drips as for TPNs, if used in a patient then you are fine to dispose of the contents via trash if empty or biohazardous trash depending on your states regs. The concern with selenium would be more on the vial side: Selenium D-101 1mg/Liter.

Re: Pharmaceutical Waste Webinar

Q: Our waste disposal company said Barium is not a hazardous waste. I checked and there is no "exception" for RCRA listed chemical in our state (Florida) is it possible that the radiology product we use is a lower concentration than 100mg/l regulatory set level?

A: As I noted it is best to check with your waste haulers as a resource. If your waste hauler ever denotes a product as being exempt, get IT IN WRITTING! There is no waivering on what RCRA states; Barium is listed as D-005 limit is 100mg/Liter. If you are below this concentration then yes it would not meet the concentration limit to be RCRA.

Re: Pharmaceutical Waste Webinar

Q: What is your recommendation for disposal of NIOSH listed "Hazardous Drugs”? Do you know if the ASHP has a list of "hazardous drugs" that differ from the NIOSH list and what list should be followed?

A: NIOSH is the FIRST and only list that have in the US of hazardous drugs from the perspective of the employee! NIOHS in my opinion holds a lot weight and I trust the judgement of the experts who compiled that list. I look at it from the stand point of unless I have a study that shows that the listed items on NIOSH are not hazardous to humans, I consider them hazardous. I know there are some directors who think opposite, but then they are NOT doing the compounding or administering.

In my opinion, I would handle these items as Yellow Hazardous Waste for disposal. It really does not cost you more and then these chemicals are properally incinerated for destruction.

Re: Pharmaceutical Waste Webinar

Q: How did you "label" your UPW items? For example "black dot" items with a sticker. Did you "label" these products electronically in the computer systems? Did you label the hazardous drugs (NIOSH) excluding chemo's that are already labeled?

A: We currently put ancillary labels on all P and U listed drugs. In addition we have electronically tagged them in Pyxis and Cerner for the nurses. However the best compliance we got was from bagging these products in a black zip lock denoting proper disposal. Again, we use black because that is the color of RCRA containers we use.

I would highly recommend getting nursing around the table to develop a process that works for them!

Re: Pharmaceutical Waste Webinar

Q: The major question for many facilities is in fact the disposal of controlled substances, what is the potential harm of destruction via the sewer system?

A: Great question and one that I will answer with ' where do we stop?' If it is OK for CS then it should be OK for paint and other products. Other than a ton of happy fish, we should not be putting anything that we mange (other than plain IVs and Irrigations) down the drain!! My point is we do not know the impact to wildlife and the potential downstream effect to humans. We have to be stewards of the environment for our products like we are stewards for our patients for excellent care. Pharmceutical care does not stop at the door it is the through the life cycle of the drugs we manage.

A: Off the record of course. First off, we do not use Demerol and since we don't I can say we ask our nurses to document and witness the waste and then squirt it out of the original delivery device into a secured sharps containter marked for incineration. Off the record.